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Corporate Compliance Insights
Home Leadership and Career

Vendor-Side Compliance vs. In-House: Accountability Drives Results

Operating in an Advisory Capacity, Effecting Change Is Out of Your Hands

by Amy Landry
July 5, 2021
in Leadership and Career
A collage combines the bottom of a banana with the top of a strawberry, an abstract representation of the difference between vendor side and in-house compliance.

Amy Landry recently shifted gears in moving from a vendor-side position advising clients to managing compliance in-house. Here, she discusses the differences in those roles and how incentive can determine the success of a program.

In my former career on the vendor side, one of my main responsibilities was to advise our customers on how the product they just purchased would help them solve <blank> need. That involved how best to implement, communicate and train their employees on this change. Now, as an in-house practitioner, my responsibility is not only to advise on an end-to-end plan (say, to launch the code of conduct), but also to execute the full plan, monitor it, and manage any changes or improvements to ensure the activity is making our program effective in preventing and detecting misconduct.

In my vendor days, I would manage five to seven customer projects at a time, but that was easy since I was just managing a small part of their program (e.g., developing an e-learning training course on anti-bribery or implementing their gifts, travel and hospitality process). Yes, I needed to understand not only their needs and pain points to provide them with the best service, but also the seven elements of an effective compliance program and the DOJ’s guidance. But this was more for demonstrating here’s how to spot a pain point and how the product will alleviate it, plus how it will help the company adhere to the seven elements guidance. In our role, we would suggest and recommend – but the work needed to handle the rollout ultimately fell to the customer. And, going forward, they had to monitor it and manage it for both improvements and effectiveness.

I would always hope that our customers would follow through on the suggestions. I didn’t want them to just add the product to a pretty paper-based program, but, instead, generate a robust and effective program. There was no guarantee, however, as I was not monitoring and managing day in and day out. Once I turned everything over to the customer, it was all in their hands.

The story is different when you’re an in-house practitioner in charge of or supporting the ethics and compliance program; you have actual skin in the game. As Matt Kelly shared in “Corporate Compliance Programs: Everything You Need to Know,

“An effective corporate compliance program demonstrates that your organization is aware of the rules and laws that apply to it, and takes reasonable, sincere steps to stay on the right side of those rules and laws.”

Bottom line: You want to help protect your organization from getting into trouble. To do this, you do everything you can to help promote an ethical culture based on your organization’s values. You review all your compliance program activities to identify the pulse of your organization – and hope to see improvement year over year.

So, this brings me to new responsibilities as I mentioned previously. I am now responsible not only for recommending or advising a plan based on a change in a law, policy or guidance (aka a need, a pain point), but also for executing that plan, monitoring to see how effective it is and, finally, making any changes to drive improvement.

It’s in my power to ensure the program is delivering on its promise, and that feels so good.


Tags: Culture of Ethics
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Amy Landry

Amy Landry

Amy Landry is an External Oversight and Risk Analyst for Vaya Health, a public managed care organization that manages Medicaid, federal, state, and local funding for services related to mental health, substance use and intellectual/developmental disabilities. Prior to joining Vaya, Amy was a Sr. Compliance and Privacy Specialist for Cardinal Innovations Healthcare and before that she spent 12 years working for multiple ethics and compliance vendors. In 2020, she began writing about her decision to make a career shift from working for a vendor to an in-house compliance post as she wanted to be more involved in the day-to-day running of a compliance program and help an organization live up to its values and ethical principles so it can better prevent and detect misconduct. She continues to contribute posts on leadership, career, and well-being for CCI. Amy is a Certified Compliance and Ethics Professional (CCEP) and Certified Information Privacy Professional (CIPP/US). She is also the author of a Data Privacy and Security compliance eLearning course with Peak Compliance Training. In her free time, Amy is a huge foodie, avid workout guru and enjoys spending time outdoors with her family.

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